International Trade Remedies

In the latest developments regarding tariffs paid under the International Economic Emergency Powers Act (“IEEPA”), the U.S. Department of Justice (“DOJ”) has formally appealed the U.S. Court of International Trade’s (“CIT”) April 17, 2026, universal injunction ordering refunds to all importers to the U.S. Court of Appeals for the Federal Circuit (“Federal Circuit”).  The DOJ has

On June 2, 2026, the United States Trade Representative (“USTR”) proposed tariffs under Section 301 of the Trade Act of 1974 (“Section 301”) on imports from 60 countries for their failure to enforce prohibitions related to forced labor. The USTR found that these failures are unreasonable and burden U.S. commerce. The proposed tariffs range from 10% to 12.5%, though they do contain several carveouts.

On June 1, 2026, President Trump issued a proclamation reducing tariff rates on certain agricultural equipment, mobile industrial equipment and machinery, and heating, ventilation and air conditioning (“HVAC”) equipment under Section 232 of the Trade Expansion Act of 1962 (“Section 232”). In the same proclamation, President Trump also added aluminum lithographic plates and steel racks

On May 29, 2026, the U.S. Department of Justice (“DOJ”) indicated that it will appeal the U.S. Court of International Trade’s (“CIT”) universal injunction ordering U.S. Customs and Border Protection (“CBP”) to reliquidate final entries (entries more than 90 days past liquidation) and refund duties paid under the International Economic Emergency Powers Act (“IEEPA”) by

On May 27, 2026, following a closed-door conference in Euro-Notions Florida v. United States (CIT # 25-00595) (“Euro-Notions”), Judge Eaton issued two (2) orders which will require U.S. Customs and Border Protection (“CBP”) to explain the Government’s position on issuing IEEPA refunds for all entries, including those that have liquidated beyond the statutory reliquidation period

On May 7, 2026, the United States Court of International Trade (“CIT” or “Court”) invalidated Proclamation No. 11012 in The State of Oregon, et al. v. United States, et al. and Burlap and Barrel, Inc., et al. v. United States, et al., holding that the President exceeded his statutory authority in imposing a temporary

U.S. Customs and Border Protection (“CBP”) has issued new guidance addressing technical corrections to recently imposed Section 232 duties on imports of aluminum, steel and copper.  Following a Notice of Technical Corrections issued by the Department of Commerce on April 29, 2026, CBP, on May 6, 2026, released CSMS #68554727 clarifying the application of these

On May 6, 2026, U.S. Customs and Border Protection (“CBP”) released new guidance via CSMS #68559236 regarding the application of 25% Section 232 duties for Medium and Heavy-Duty Vehicles (“MHDVs”) that qualify for preferential treatment under the United States-Mexico-Canada Agreement (“USMCA”).  Pursuant to Presidential Proclamation 10984, the Secretary of Commerce may approve eligible MHDVs to

On April 20, 2026, U.S. Customs and Border Protection (“Customs”) announced the activation of Phase 1 of the Consolidated Administration and Processing of Entries (“CAPE”) for IEEPA tariff refunds. CAPE Phase 1 is limited only to certain unliquidated entries and certain entries within 80 days of liquidation. For more information about CAPE as well as

U.S. Customs and Border Protection (“CBP”) issued guidance on how importers need to report and classify goods subject to the revised steel, aluminum, and copper tariffs announced by the Trump Administration on April 2, 2026. We encourage importers to review the list of HTS number affected by the metal tariffs to ensure compliance with the below reporting requirements.